Tax Type
Corporation Income Tax
Description
Combined Return
Topic
Corporate Distributions and Adjustments
Date Issued
12-10-1982
December 10, 1982
Re: § 58-151.079: Permission to File a Combined Return
Dear ****************
The parent corporation has applied for permission to file a combined Virginia return including itself and its subsidiaries doing business in Virginia for calendar year 1981 and thereafter. The corporations have riled separate Virginia returns in prior years.
Our records indicate that the affiliated group includes a Domestic International Sales Corporation (DISC) which the Department of Taxation has previously required to be consolidated with its parent under § 58-151.083. This letter has no effect on the Department's treatment of the DISC under § 58-151.083 and the DISC should continue to be consolidated with its parent.
Permission is hereby granted to file a combined return for taxable years beginning on or after January 1, 1981 which includes all affiliates doing business in Virginia upon the following conditions:
1. Schedules shall be filed with the combined return which contain all information which would be contained in a separate Virginia return or each and every eligible member of the affiliated group. See §§ 58-151.079 and 58-151.081.
2.. In computing the Virginia Taxable Income of each eligible member of the affiliated group there shall be added to federal taxable income the amount of any net operating loss deduction or other deduction which has been recognized for Virginia income tax purposes and offset other income in a Virginia consolidated or combined return for other taxable years. See, for example, Federal Income Tax. Regulation 1.1502-79.
Sincerely,
W. H. Forst
State Tax Commissioner
Rulings of the Tax Commissioner